Last updated: April 23, 2025
This privacy policy adds to the information at prefrontalcortex.de/kontakt. Where the policies differ, the one at prefrontalcortex.de is binding.
This privacy policy governs your use of our software applications ("Applications") that were created by prefrontal cortex. The Applications are used for a variety of purposes, ranging from gaming to interactive narratives and specialized industry content. Each application also has a separate privacy policy that you can reach from the application's homepage.
For the purposes of applicable data protection laws, including the EU General Data Protection Regulation (GDPR), prefrontal cortex, located in Germany, is the data controller responsible for your personal information. If you have any questions about this Privacy Policy or how we handle your personal information, please contact us at contact@prefrontalcortex.de.
User Provided Information
The Applications do not collect or process personal user identification information.
For our VR Applications, we want to be transparent about data processing in accordance with VRC.Quest.Privacy.2 requirements:
Temporary Local Data Processing: Our VR application temporarily processes certain technical data locally on your device that is required for core functionality, including:
Exception for User-Requested Recording Features: In cases where the explicit purpose of an application is to record avatar data or other user interactions (such as motion capture, avatar customization tools, or recording features), and the user specifically requests this functionality, the relevant data will be stored as required to fulfill this purpose. In such cases:
Important Privacy Note: Unless explicitly stated otherwise for specific recording features as described above, all processed data is:
Our applications are designed with privacy by design principles, ensuring that technically required data processing is minimal, temporary, and contained within your device.
Automatically Collected Information
The Applications do not automatically collect or transmit information about your device or usage. While some technical data (such as device performance metrics) may be temporarily processed locally for the application to function properly, this information never leaves your device and is not accessible to us or any third parties.
We prioritize user privacy and data minimization in our application design.
Under GDPR and other applicable data protection laws, we process your personal data based on the following legal grounds:
These Applications do not collect precise information about the location of your mobile device or VR headset.
For Apple App Store Applications: Our Applications do not use the Apple App Tracking Transparency framework as we do not track users across apps or websites owned by other companies or use information for targeted advertising purposes. We do not use third-party advertising SDKs in our Applications.
For Google Play Applications: Our Applications do not request sensitive permissions such as access to contacts, camera, microphone, or location unless strictly necessary for application functionality. When such permissions are requested, they are optional and clearly explained within the Application.
Only aggregated, anonymized data is periodically transmitted to external services to help us improve the Application and our service. We will share your information with third parties only in the ways that are described in this privacy statement.
We may disclose User Provided and Automatically Collected Information:
as required by law, such as to comply with a subpoena, or similar legal process;
when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
with our trusted services providers who work on our behalf, do not have an independent use of the information we disclose to them, and have agreed to adhere to the rules set forth in this privacy statement.
if Felix Herbst, prefrontal cortex is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of this information, as well as any choices you may have regarding this information.
Your personal information is primarily stored and processed in Germany, within the European Economic Area (EEA). In situations where data may be transferred outside the EEA, we ensure appropriate safeguards are in place in accordance with data protection law, such as standard contractual clauses or adequacy decisions from the European Commission. For more information about these safeguards, please contact us at contact@prefrontalcortex.de.
You can stop all collection of information by the Application easily by uninstalling the Application. You may use the standard uninstall processes as may be available as part of your device or via the application marketplace or network. You can also request to opt-out via email, at contact@prefrontalcortex.de.
Our Applications may use local storage mechanisms or similar technologies to store certain preferences or settings on your device to improve your experience. These are not used for tracking purposes across different applications or websites. You can clear this data by uninstalling the Application or through your device settings.
We will retain User Provided data for as long as you use the Applications and for a reasonable time thereafter. We will retain Automatically Collected information for up to 24 months and thereafter may store it in aggregate. If you'd like us to delete User Provided Data that you have provided via the Application, please contact us at contact@prefrontalcortex.de and we will respond in a reasonable time. Please note that some or all of the User Provided Data may be required in order for the Application to function properly.
If you are a resident of the European Economic Area (EEA), you have the following data protection rights:
To exercise these rights, please contact us at contact@prefrontalcortex.de.
All users, regardless of region or location, may request deletion of any data collected about them through our Applications by:
We will process all deletion requests within 30 days and confirm completion via email. There are no fees associated with requesting deletion of your data. In cases where we cannot fulfill a deletion request (such as data required by law to be maintained), we will provide a clear explanation.
We do not use the Applications to knowingly solicit data from or market to children. For users in the United States, children are defined as under the age of 13 under the Children's Online Privacy Protection Act (COPPA). For users in the European Union, children are defined as under the age of 16 (though some member states may have a lower age threshold) under the General Data Protection Regulation (GDPR). If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at contact@prefrontalcortex.de. We will delete such information from our files within a reasonable time.
We are concerned about safeguarding the confidentiality of your information. We provide physical, electronic, and procedural safeguards to protect information we process and maintain. For example, we limit access to this information to authorized employees and contractors who need to know that information in order to operate, develop or improve our Application. We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including encryption of personal data where appropriate. Please be aware that, although we endeavor provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.
This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy here and informing you via our messaging channels. You are advised to consult this Privacy Policy regularly for any changes, as continued use is deemed approval of all changes.
By using the Applications, you are consenting to our processing of your information as set forth in this Privacy Policy now and as amended by us. "Processing," means using cookies on a computer/hand held device or using or touching information in any way, including, but not limited to, collecting, storing, deleting, using, combining and disclosing information, all of which activities will take place in the Germany. If you reside outside the Germany your information will be transferred, processed and stored there under Germany privacy standards.
If you are a resident of the European Economic Area (EEA) and believe we maintain your personal data subject to the GDPR, you may direct questions or complaints to the German Federal Commissioner for Data Protection and Freedom of Information (BfDI) or your local supervisory authority.
If you have any questions regarding privacy while using the Applications, or have questions about our practices, please contact us via email at contact@prefrontalcortex.de.